DOCUMENT REQUESTS
Please produce the documents set forth in Schedule A, provided, however, that in order to facilitate production of documents on an expedited basis, you may limit your production at this time to documents you furnished at any time after November 8, 2016 to: (a) the Special Counsel’s Office established by Department of Justice Order No. 3915-2017 (May 17, 2017); (b) the United States Attorney’s Office for the Southern District of New York (“SDNY”); (c) any other federal or state regulatory and/or law enforcement agency; (d) any congressional committee; or (e) in civil or other litigation. This includes but is not limited to documents that were voluntarily provided, produced under compulsion, or seized. Instructions for producing documents appear in Schedule B, and definitions appear in Schedule C.
SCHEDULE A
1) All documents relating to the following:
a) The June 9, 2016 Trump Tower meeting, including but not limited to contacts or communications about the meeting involving one or more of the following individuals: Donald Trump Jr., Natalia Veselnitskaya, Donald Trump, Paul Manafort, Jared Kushner, Emin Agalarov, Aras Agalarov, Rob Goldstone, and/or Rinat Akhmetshin.
b) The “Republican Platform 2016” provisions relating to Russia and Ukraine, including, but not limited to, the exclusion of language related to providing lethal defensive weapons to Ukraine and the inclusion of language about providing “appropriate assistance” to the armed forces of Ukraine.
c) Discussions or attempts to provide or receive election information, campaign data, or campaign communications with, to, or from foreign entities or individuals in connection with the 2016 U.S. Presidential primary or general elections. This includes, but is not limited to, voter data, polling information, political ad targeting, voter registration rolls, social media data, and campaign or party e-mails.
d) Discussions of United States imposed sanctions or potential sanctions against the Russian Federation from June 16, 2015 to January 20, 2017 (including but not limited to the sanctions imposed pursuant to the Magnitsky Act) involving one or more of the following individuals: you, Donald Trump, the Trump Campaign, the Trump Organization, Paul Manafort, Rick Gates, Michael Cohen, Michael Flynn, Jeff Sessions, Jared Kushner, Thomas Bossert, Roger Stone, Jerome Corsi, George Papadopoulos, Konstantin Kilimnik, K.T. McFarland, and/or Erik Prince.
e) Any contacts, direct or indirect, from January 1, 2015 to January 20, 2017 between or involving the Russian Federation and its officials, agents, intermediaries, and/or instrumentalities and any of the following: you, Donald Trump, the Trump Campaign, the Trump Organization, Paul Manafort, Rick Gates, Michael Cohen, Michael Flynn, Jeff Sessions, Jared Kushner, Thomas Bossert, Roger Stone, Jerome Corsi, George Papadopoulos, Konstantin Kilimnik, K.T. McFarland, and/or Erik Prince.
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Carter Page
f) Any contacts, direct or indirect, from January 1, 2016 to the present between or involving Wikileaks and its officials, agents, intermediaries, and/or instrumentalities. g) Any contacts, direct or indirect, from January 1, 2016 to the present between Paul Manafort and/or Rick Gates and any of the following individuals: Konstantin Kilimnik, Serhiy Lyovochkin, and/or Rinat Akhmetov. h) Any contacts, direct or indirect, from January 1, 2016 to the present between Michael Cohen and any of the following: Viktor Vekselberg, Andrew Intrater, or Columbus Nova or its officials, agents, intermediaries, and/or instrumentalities.
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